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May 15, 2022

Qualified See-Through Trust beneficiary

Your Guide


Qualified See-Through Trust

A trust that meets certain specific requirements that makes it a designated beneficiary


A qualified trust beneficiary is a trust that satisfies the requirements so as to be treated as a designated beneficiary.   For retirement accounts inherited before 2020, the life-expectancy of the oldest trust beneficiary’s would be used for life-expectancy distributions. For retirement accounts inherited after 2020, the 10-year rule would apply to a trust that is  designated beneficiary, and the life-expectancy option would be available only if the trust is an eligible designated beneficiary.

A trust is a qualified trust if it meets the following requirements:

  1. The trust is a valid trust under state law, or would be but for the fact that there is no corpus.
  2. The trust is irrevocable or will, by its terms, become irrevocable upon the death of the employee.
  3. The beneficiaries of the trust who are beneficiaries with respect to the trust’s interest in the employee’s benefit are identifiable
  4. The trust documentation, showing the designated beneficiary as of September 30 of the year follow the year of death,  has been provided to the plan administrator or IRA custodian/trustee by October 31 of the year following the year-of -death. There must be an agreement to provide the IRA custodian/plan trustee of any future  amendment made to the trust.  The documentation may be a list of the trust beneficiaries of a copy of the trust.

The documentation requirements for a trust to be a qualified see-through trust for beneficiary distribution purposes the trustee of the trust must provide a list of beneficiaries or a copy of the trust instrument to the plan trustee/IRA custodian by October 31 of the calendar year immediately following the calendar year in which the participant died.

If providing a list of beneficiaries, the trustee must:

  • Provide the plan administrator or IRA custodian with a final list of all beneficiaries of the trust as of September 30 of the calendar year following the calendar year of the death (including contingent beneficiaries) with a description of the conditions on their entitlement sufficient to establish who are the beneficiaries.
  • Certify that, to the best of the trustee’s knowledge, this list is correct and complete and that the requirements for the trust to be a qualified see-through trust are satisfied; and
  • Agree to provide a copy of the trust instrument to the plan administrator/IRA custodian upon request.

If providing a copy of the trust, the trustee must provide the plan administrator with a copy of the actual trust document for the trust that is named as a beneficiary as of the participant’s date of death.

Referring Cite

Treas. Reg. §1.401(a)(9)-4, Q&A-5

Additional Helpful Information

  • If the spouse of the participant is the sole beneficiary of the trust, the participant may apply the RMD calculations rules that would apply had the spouse been the direct beneficiary

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